SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
The Kyoto Target
(a) It
is now widely accepted that the UK must meet its Kyoto target
for reductions in greenhouse gas emissions and further more stringent
targets thereafter. The question is how, not whether, greenhouse
gas emissions can be reduced. In
order for the UK to meet its legally-binding 12.5% target for
reductions in greenhouse gas emissions, action is required to
prevent CO2 emissions increasing over the course
of the next decade (paragraphs 6 and 9).
Meeting the Target
(b) We
share Lord Marshall's view that all sectors of the economy must
contribute to reductions in greenhouse gas emissions. The Government
must not make industry bear the brunt of the emissions reductions
required for the UK to meet its Kyoto target because of the perception
that this might be the easiest and politically most expedient
course. We believe that the Climate Change
Levy could improve the energy efficiency of at least some of the
UK's industrial and commercial sectors and thereby reduce carbon
dioxide emissions. Although the Climate Change
Levy might assist the UK hit its Kyoto target for reductions in
greenhouse emissions, it will not be the only tool necessary for
the job, all the more so if the Government has serious ambitions
of achieving its target of a 20% reduction in CO2
emissions from 1990 levels by 2010 (paragraphs 6, 10 and 20).
(c) We
are not persuaded that the Government can set emissions reductions
targets, or establish effective monitoring and compliance procedures,
for the great majority of small and medium sized enterprises.
Nor are we convinced that the Government is better able than the
market to steer firms towards the energy efficiency improvements
needed to cut emissions. Indeed, we were surprised by the enthusiasm
expressed by so many business representatives for Government intervention
in their industries when we have become accustomed to the mantras
that "the market knows best" and "the Government
should regulate with a light touch". Regulatory approaches
to emissions reductions have a role to play in ensuring the UK
meets its Kyoto target, but we reject the argument that regulation
by itself will prove sufficient (paragraph 13).
(d) We
were surprised to hear of the depth of the Minister for Energy
and Industry's commitment to emissions trading. The Government
has sent out mixed messages on the feasibility of a national carbon
emissions trading scheme being quickly introduced. We see no reason
why the UK should hold back from developing its own carbon emissions
trading scheme ahead of the proposed international scheme, which
the UK might be in a strong position to influence. We seek early
clarification from Government of its views on whether a national
carbon emissions trading scheme, if feasible, should be introduced
prior to the start of an international scheme (paragraph 15).
(e) One
of the major aims of the Climate Change Levy is to incentivise
small and medium sized enterprises, many of whom are not likely
to become involved in emissions trading, to use energy more efficiently.
The Levy cannot therefore be dismissed as a short term measure,
introduced in lieu of emissions trading and likely to be abolished
once such trading begins in earnest (paragraph
16).
Impact of the Levy
(f) We have
been disturbed by the unprecedented scale of the reaction to the
Government's proposal. We share the view expressed by several
witnesses that, without appropriate modifications and exemptions,
the Levy could prove a blunt instrument which does considerable
damage to sectors of the British economy already struggling to
maintain their profitability (paragraph 26).
(g) It is imperative
that the Levy makes special provisions for energy intensive industries,
such as to minimise any damage to their international competitiveness
(paragraph 26).
(h) The Government
must pay attention to the regional, as well as the sectoral, effects
of the Climate Change Levy, especially in relation to Northern
Ireland, which has an entirely different energy market to that
operating in the rest of the UK (paragraph 27).
(i) There will be
gainers from the Levy, such as, for instance, the financial sector,
but any competitiveness gains they might make if the Levy was
introduced have so far been overlooked (paragraph 25).
Recycling Revenues
(j) We received
the distinct impression that there was considerable confusion
over the meaning of the phrase "revenue neutral", and
that some witnesses had wrongly assumed that it was intended to
convey the impression that no firm or sector would lose out as
a result of the introduction of the Levy. The phrase is not even
an accurate description of the Levy's effect on public finances,
since there will be a net saving on public expenditure due to
the public sector's reduced liability for National Insurance contributions
(paragraph 28).
(k) As with the need
for a broad range of policy options to pursue reductions in greenhouse
gas emissions, we believe that there should be a diversity of
approaches to recycling the revenues raised by the Levy to the
business and commercial sectors. More subtle mechanisms are required
than those proposed in order to prevent inequitable distributional
impacts which might harm British industry. We are attracted by
the option of using tax incentives which promote energy efficient
investment to recycle at least some of the revenues raised by
the Levy. We recommend that the Treasury seriously consider this
option, and, if they choose to reject it, explain in detail the
basis for their decision (paragraph 30).
(l) We are loath,
at this stage, to press for an increase in the size of the fund
intended to be set up to channel some Levy revenues into energy
efficiency and renewables projects when there is so much uncertainty
as to its intended functions. We recommend that the Government
publicly consult on the options for distributing the fund. We
also suggest that the Government indicate its long-term plans
for the fund, including the circumstances in which the size of
the fund might be increased (paragraph 32).
Carbon or Energy Tax?
(m) There
would appear to be some confusion within Government about the
extent to which the Climate Change Levy could and should reflect
the carbon content of fuels. A full carbon tax would clearly
conflict with DTI policy on the use of coal and gas for electricity
generation. On the other hand, there is a logic deficit inherent
in the proposal that electricity generated by fuels which do not
cause greenhouse gas emissions should be taxed at the same rate
as electricity generated by fuels which do cause such emissions.
We recommend that the Government seek ways to link the Levy,
at least broadly, to the carbon content of fuels (paragraph 36).
(n) We recommend that
ways are found to exempt from the Levy electricity generated by
renewables technologies without excluding those for which there
are no curent plans for new plant (paragraph 37).
(o) We are not convinced
by the Government's case for ruling out an exemption from the
Levy for electricity generated by nuclear plant (paragraph 38).
(p) We recommend that
the Government use the design of the Climate Change Levy to give
a fiscal boost to the installation of CHP capacity in the UK (paragraph
39).
Treatment of Intensive Users of Energy
(q) The IPPC
regime is designed to deal with industrial pollution and is only
indirectly related to the energy intensity of industry. Administrative
convenience would seem to be the only reason why the Government
has chosen to use IPPC coverage to define energy intensive industries.
We understand that DTI is updating its ten year old figures on
energy use by UK industry. These figures should be used to specify
which firms and plant are energy intensive and therefore deserve
special treatment under the Levy. The use of other, less accurate,
measures of energy intensity is likely to create anomalies and
inequities which will serve only to discredit the Levy (paragraph
41).
(r) DETR's door seems
to be open to a wide range of firms seeking special treatment
under the Levy. We seek clarification from the Government of those
sectors with which it is currently negotiating agreements on energy
efficiency. We are concerned, however, that the Government is
considering negotiating 25 or more agreements, some with sectors
which are not intensive users of energy, when the efficacy of
such agreements is untested, and the experience reported by the
chemical industry less than persuasive (paragraphs 42 and 44).
(s) There will not
be negotiations between industry and the Treasury about the reductions
in the rate of Levy offered as a result of energy efficiency agreements
being reached these will be decided within Government,
possibly entirely within the Treasury. The mechanism, if such
exists, by which information about the quality of the agreements
reached can be factored into the process of deciding the reductions
to offer firms is not obvious, particularly since the Treasury
is not represented in the talks between DETR and industry representatives.
We ask the Treasury to think again about the way in which it intends
to offer reductions in the rate of Levy to firms. This approach
has done nothing to encourage a cooperative relationship between
Government and industry on emissions reductions and we are concerned
about the investment implications of the uncertainty about the
rates of Levy which will apply to many major UK manufacturing
industries (paragraph 43).
Government Energy Policy
(t) The Government's
policy on the taxation of energy use is pulling in a different
direction to the commitment of DTI and the Office of Gas and Electricity
Markets to reduce energy prices. If energy prices continue to
fall then the signal which the Climate Change Levy is intended
to give to industry about the importance of energy efficiency
will be obscured. The conflict between these two aspects of the
Government's energy policy must be urgently addressed, particularly
if businesses are to receive some indication of the long-term
direction of that policy, as Lord Marshall recommended (paragraph
21).
(u) There is a tension
between the Government's desire to protect the coal industry and
the need to cut back carbon dioxide emissions which, at least
partly, explains the reluctance to link the taxation of energy
use to the carbon content of fuels (paragraph 34).
Policy making
(v) We are
disappointed that the Government, despite a welcome commitment
to consult on financial proposals, failed to consult on several
of the key decisions determining the design of the Climate Change
Levy. At the very least, this has undermined the potential for
Government and industry to work closely together on reducing the
UK's greenhouse gas emissions (paragraph 46).
(w) We remain to be
convinced that the Treasury has not seen the Climate Change Levy
as an opportunity for the Chancellor to offer the majority of
the business and commercial sectors a significant tax cut, by
reducing employers' NICs, in his next Budget (paragraph 47).
(x) The Government
needs to be aware of, and make use of, the best practice of other
countries in relation to energy taxation, not least to help uphold
the international competitiveness of UK firms once the Levy is
introduced (paragraph 49).
(y) We hope that the
forthcoming meeting between Ministers and industry representatives,
announced for the first time at, and possibly in response to,
the Committee's evidence session on 6 July, will mark a new approach
by the Government to its consultations about the introduction
of the Levy. We expect the Government to work closely with industry
to achieve energy efficiency gains which do not harm, and indeed
might improve, the international competitiveness of industry
the "win, win" situation Ms Hewitt mentioned to us.
Recent actions by the Government, particularly the decision taken
without consultation, to recycle almost all the revenues of the
Levy by cutting employers' NICs, have raised serious concerns
about the effect the Levy might have on energy intensive sectors
(paragraph 50).
The Way Ahead
(z) We anticipate
that the Chancellor will be moving the debate on the Climate Change
Levy forward when he releases his pre-Budget report in the autumn.
We intend to keep the announcements he makes on the Levy under
close scrutiny (paragraph 51).
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